4. COMMERCIAL MAILINGS
At PGI and SP we will process the data you supply us with in order to send you commercial mailings where we have obtained your prior consent for this. If you give your consent we will send you information, advertising, surveys, invitations to events or promotions concerning products or services relating to the activity of PGI and SP. At the moment of data being gathered you may as a Customer decide whether or not you wish to receive this type of mailing from us, and you may always withdraw your consent at any time.
If you agree to us sending you commercial mailings electronically (email, SMS, instant messaging or social networks among others), you must bear in mind that all mailings sent by PGI and/or SP may be adapted and personalized according to your interests, either on the basis of the products and services you have ordered or for example any data we can deduce or obtain from your browsing habits, interest in particular content or reaction to our mailings, as explained in the section above “Preparation of Profiles”.
This personalization is partially automated in the sense that PGI and SP determine the parameters of the personalization but it is the technological platform which generates the Customer profile. As a general rule we do not send general mailings not segmented by way of this process as we think it is in the interests of both us and our Customers to send and receive information which is relevant, and because not segmenting would not alter the number of mailings received, only their content. In this regard if you do not wish to be segmented for advertising purposes we would ask you not to subscribe to PGI and/or SP mailings or the Newsletter.
The commercial mailings sent electronically referred to above may be sent by the following channels:
Mailings by email, SMS or MMS o direct messaging (whatsapp, telegram, Facebook Messenger, direct messages in forum or social network applications, etc). If we have the relevant information (email, mobile telephone number, etc.) we can send you commercial mailings by these means. As a general rule the channel of communication will be just email, wherever possible, although some messages may be sent by another of the means indicated (e.g. the sending of reminders, events or surveys).
Commercial mailings in third party platforms (e.g. social networks):
Some third party platforms (i.e. websites, communities or applications, for example) allow other advertisers to use the platforms to advertise directly to PGI and/or SP customers who also have a user account in the platform.
For this the platform may require the advertiser to prove the identity of its Customers, providing basic identification data such as for example an email address or a telephone number in an encrypted form protected by way of tools provided by the platform itself.
Once the identity of the Customer and the existence of a user account in the platform have been established San Patrick can create what is commonly known as a “personalized public” with those customers who have agreed to receive advertising in the platform, with San Patrick advertising appearing directly in the user profile.
For example in social networks this type of activity can be found in Facebook (Custom Audience), Twitter (Personalized audiences) or Google (Customer Match).
The purpose of this activity is essentially one of advertising and hence your data is only used if you have agreed to receive our mailings.
These third party platforms may also allow advertisers such as Pronovias to use their tools to identify users who, within their platform, have a “similar profile” to Pronovias customers.
The procedure for identifying and proving the identity of customers is the same as above.
For example in social networks this type of activity can be found in Facebook (Lookalike Audience), Twitter (Personalized audiences) or in Google (Similar Audiences).
In this case, as the data is not used directly for advertising to our Customers, being aimed at persons who are not customers but have a profile similar to our customers, we will use the basic data of all of our Customers (and not just those who have agreed to receive advertising) to identify potential customers in the platform. In this way the advertising will be sent only to those potential customers who have given their consent to the platform in question for the sending of advertising. This processing is carried out on the basis of our legitimate interest in expanding our customer base, but you may object to your data being processed for these purposes at any time.
As stated above these services only ask for basic identification data, i.e. we do not supply all of your personal data, or any preferences we are aware of, we merely provide an email account or telephone number which is shared in encrypted form and protected by tools provided by the platforms themselves, sufficient for the social network to identify you in its database.
Secure communication techniques are also used, including the encryption of data before uploading it, to ensure the confidentiality and security of the information.
Finally we do not obtain data about you directly from these third party platforms, i.e. we may obtain anonymous and statistical information but never precise information on your interests or whether you have seen a particular advertisement, unless you interact with us or the particular advertisement.
If you do not wish us to use your data for advertising purposes in third party platforms you may contact us at the email and postal addresses given below. If we are already using it in these platforms we will erase it in the following update of the data supplied.
You may withdraw your consent to the sending of electronic commercial mailings at any time simply by following the instructions given at the foot of all electronic mailings sent by PGI and/or SP or by sending an email to the address firstname.lastname@example.org or writing to Via Montenapoleone 8, 20121 Milano, enclosing in both cases a copy of your identity document or passport and indicating “Ref. Data protection” on the envelope (if you are using post) or in the reference field (if you are using email) and stating that you wish to withdraw your consent to the sending of electronic commercial mailings.
5. WHAT INFORMATION DO WE SHARE WITH THIRD PARTIES?
Your data will not be assigned, sold, hired out or in any other way made available to any third party, except for service providers of PGI and /or SP who provide certain services for us (for example the sending of the newsletter, marketing or customer service suppliers, data and database storage or handling, transport or logistics suppliers, Forums or Social Networks in which we advertise, etc.), but not for their own purposes. Our stores may also access the data but not use it without our consent or without following the instructions given by PGI and /or SP.
Notwithstanding this, we remind you that if you acquire our products or order certain services by way of the Website (such as, for example, booking an appointment) it may be necessary to communicate all or part of your personal data to third parties in order to process the purchase or service, for example:
- your personal and contact data, which it may be necessary to send to the store where you have made the booking in order for them to contact you and conform the appointment, and inform you of any incident in relation to the same;
- your contact, address and delivery data, which it may be necessary to send to transport and messenger companies for them to be able to process the product purchases you make with us and deliver them to where you indicate; or
- your personal data and/or method of payment data, which are processed directly by the secure payment services platform Adyen, which processes it in its own name to process the transactions you carry out with us. This may include exchange of information with other companies and organisations for protection against fraud and reduction of credit risk.
In accordance with current regulations San Patrick will only send the personal data of Customers which is strictly necessary, and the third parties receiving the same may only process your personal data to process the purchase of the product or service in question unless we expressly inform you of any additional processing.
- Standard clauses approved by the EU: These are contracts approved by the European regulator and which provide sufficient guarantees that the processing complies with the requirements laid down in the European Data Protection Regulation.
- Third party certificates: For example, the Privacy Shield, a framework agreement between the EU and the United States which provides a standardised framework for data processing in accordance with the requirements of the European Data Protection Regulation.
Outside the cases specified above, PGI and/or SP will not disclose, transfer, sell or rent personal information that you provide to us through the Website to third parties, except when disclosure is required by law, by court order, or by a competent authority, as well as when we must communicate the data essential for the logical reason of providing the service or is expressly requested by obtaining your prior express consent for communication to third parties.
6. DURATION OF PROCESSING AND PRESERVATION OF DATA
As a general rule we process the data for the time necessary for the maintenance of the appropriate commercial relation.
For example your Customer Account will be preserved for a period of 5 years from your last interaction in Pronovias or Pronovias Online, which includes use of our website, reading our electronic communications or visiting any of our stores. Any data we collect from you in connection with our Real Brides project, either through our website, social media and/or Photoslurp project or via Photoslurp, will be kept for a period of 5 years from the day of collection, unless you choose to withdraw your consent or unless we are otherwise required to keep it due to local legislation, to comply with any judicial orders or requests from authorities, or for the purposes of defending any legal claims.
If you have subscribed to our commercial mailings your personal data will be preserved until you cancel the subscription or you expressly request that your data not be used in third party platforms (being eliminated from the same), or we decide or ascertain by any means available in the technology of the time that our mailings do not interest you, for example because you do not browse the website or you do not open our emails.
We will inform you of the preservation time of your data in the various forms in which personal data is requested, without prejudice to your data being preserved for a longer period duly anonymized for statistical or market research purposes, wherever possible or blocked to comply with legal obligations (for example the Consumer Protection Act and commercial or tax regulations may oblige us to preserve certain data for a specific period of time).
7. YOUR OBLIGATIONS AS A CUSTOMER
On sending your data to PGI and/or SP by any medium (by email, telephone, instant messaging applications, Forums and Social Networks or by way of any of the data gathering channels available in the Website), you undertake that the data you are supplying corresponds to your true identity and that the said data is updated, truthful, accurate and complete at the time at which you supply it. You are solely responsible for the truthfulness, accuracy and completeness of the personal data you supply and hence you must inform PGI and/or SP as quickly as possible of any change or alteration of any personal data you have provided us with. Remember also that personal data is the property of each person, and it is thus totally prohibited to supply to PGI and/or SP any third party data or information without their prior consent (for example, if you give the address of a relative as the address for the delivery of an order you must tell them you are passing their data to PGI and/or SP, and that they can access this Policy in our website).
As a Customer you will be solely liable for any direct or indirect damage or loss caused to PGI and/or SP and/or third parties as a result of breach on your part of the obligation to provide truthful, accurate, complete and updated information corresponding to your true identity.
If you register on the Website remember your password is secret, personal and non-transferable and that you as the Customer are solely responsible for maintaining its confidentiality and secrecy. For this reason we recommend you pay particular attention when entering your personal data, especially bank data, and that you do not share your registration code or password with third parties. Any damage or loss caused directly or indirectly to PGI and/or SP and/or to third parties under your password and registration code will be solely your responsibility.
8. YOUR RIGHTS AS A CUSTOMER
As a User you have the right to access your information, to rectify it if the details are incorrect, to opt out of the processing of your details, to delete them, to limit the processing or to transfer your details. You may also withdraw any consent given at any time. Please note that if at the time of exercising any right this could prevent the provision of any outstanding service, such as sending the product to your home if you request that we delete your data.
To exercise your rights of access, correction, erasure, restriction or portability in relation to any data you have supplied you just have to contact PGI and/or SP, which will centralize handling of the rights exercised in relation to the processing of your data, either by email at email@example.com or by writing to Via Montenapoleone 8, 20121 Milano, enclosing in both cases a copy of your identity card or passport and indicating “Ref. Data protection” as a reference on the envelope (if you use post) or the reference field (if you use email) and clearly explaining the right you wish to exercise and the data necessary for such exercise.
9. DATA SECURITY
The Website contains the appropriate safeguards and uses technology based on the industry standards to improve the security, integrity, confidentiality, availability, exhaustiveness, accuracy and protection of the personal data it has compiled, and has taken reasonable precautions to protect this information from possible loss or misuse. The rules on data protection and security are reviewed on a regular basis and improved where necessary, with reasonable measures being adopted to ensure that only authorized persons are able to access the information you supply.
Despite this, although we make an effort and use all means at our disposal to ensure the security, confidentiality, availability, inviolability and integrity of your data, we are not able to guarantee absolute technical security as a medium like the Internet is not impregnable and malicious actions on the part of third parties may occur which are beyond the control of PGI and/or SP.
In no case and under no circumstances will PGI and/or SP be liable for damages or losses derived from causes not attributable to PGI and/or SP such as, by way of example and in no way limited to, viruses, harmful components, malfunctioning of the browser, computer intrusions or attacks by third parties.
10. COOKIES POLICY
We make all information on the cookies we use in the Website in our Cookies Policy.